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As an example, German Presidents are limited to two terms of five years and have little power in practice. However the German Chancellor is not limited by term limits despite having more power and influence and Angela Merkel has served in the position for more than 13 years as of today. We can find similar term limits in other parliamentary democracies, such as Czech Republic or Austria.

What is the reasoning behind this? Is it a historical relic from the time when Presidents had more influence on the state?

  • To some extent it is probably a relic from when the President could dismiss the PM at will (Weimar republic, IIRC). I don't know what's the reason to have PM terms uncapped even when the dismissal-at-will provisions went away. – Fizz Apr 28 at 2:02
  • No. Typically in systems like this the Prime Minister (or other similar but equivalent title) is not an elected post. The people elect the parliament, the parliament proposes a government, the government is either approved or disproved by a President whose job is mostly ensuring that stuff is done accordingly to the constitution (and usually has the power of bringing down the government by dissolving the parliament and calling new elections). So the President (again, usually) has no administrative power, but has the power to ensure the correct functioning of the democratic institutions. – armatita Apr 30 at 13:26
  • Oh, and another important point is that the President position is typically not without its own checks and balances. Positions such as General Prosecutor, President of the Supreme Court, and President of the Parliament (which are jobs with very little influence by comparison), among others, can call for the destitution of a President within a given criteria (inability to physical perform the job, death, crime, absence from country, etc.). – armatita Apr 30 at 13:53
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The Prime Minister can be dismissed by a vote of confidence, or in some systems the Prime Minister can be dismissed at the will of the President. The President (in many such systems) cannot. The incumbency advantage can lead to a president remaining in office indefinitely, and using their position to place a chosen successor in the role after they leave. The "two-term" rule is a guarantee against a President becoming a monarch.

There is a Parliamentary mechanism for removing a Prime Minister. There does not need to be a term limit.

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    I'm not convinced this fully answers the question. How are repeated elections (without term limits) more likely to enable a "monarchy" than the PM dismissal procedure that may never happen? – Fizz Apr 28 at 6:55
  • I'm suggesting that there is one mechanism to ensure that a PM doesn't get too powerful: she needs parliamentary support. And another to stop the president: He has to quit after two terms. – James K Apr 28 at 14:51
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The usual case is that the PM is PM by dint of heading up the largest party, as such a term limit would effectively be interfering with party politics. Also, the powers tend to be based on being the party of government, whilst a president has powers beyond those. Another consideration is history. Presidential systems evolved as a replacement for monarchy so term limits were seen as part of the avoidance of a new monarchy. Prime minister as an office simply does not have that history. As many set ups are based on others, this pattern tends to reoccur.

  • Almost true, but there's a common misconception about parliamentary systems. You see, the PM is not the leader of the largest party, but the person that has gained parliamentary support. Typically these are the same person but the distinction is important as was seen in the latest Portuguese General elections. A right wing coalition had the most votes, but the majority of votes were scattered in several center to left wing parties. The result was a center-left government. – armatita Apr 30 at 15:44
  • @armatita indeed, you are correct, but I said "The usual case" – Display name Apr 30 at 16:42
  • I didn't say otherwise. In fact in most situations you analysis is correct. The reason why I think it's important to go in depth into this subject is due to the OP question. I believe that same misconception exists there. There are term limits to the position voted directly by the people, not to the one voted by the parliament. And there might be some very good underlying logic that justifies this. Just look at the recent examples of Venezuela and Turkey. Democracy failed because the population was lead to vote in a charismatic, but ultimately, autocratic individual. – armatita May 2 at 8:07
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One of the most important points is that just like Orangesandlemons said presidents were as a replacement for monarchies, so one of the most important aspects of a president was that he served temporarily. Another important part is a lesser known fact: The role of prime minister already existed for hundreds and even thousands of years, with an equivalentof a Prime minister already existing during the rule of the egyptian pharaohs. Prime ministers were justthe people who took care of the normal boring part of ruling in the name of the kings and queens of europe, they served at their pleasure and discretion. That's when democratic aspects were added to monarchies those people who were de facto already ruling the country just kept doing that but had to answer to for example some form of parliament. It was only after parliaments got more powerfull that they in fact took control of the position by choosing one of their own to fill it. Although the power of the position fluxuated through history, the basic concept didn't really change, and so in most places the rules didn't either.

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You specifically cite the German example so I will provide some German input.

In the consitution of the Weimar Republic of 1919, the president gained a position that is often referred to in history books as a replacement emperor. He had vast powers, appointed the government, could dissolve the parliament and decree ‘emergency laws’. He was elected for a seven-year term and could be reelected indefinitely. However, the Weimar Republic only lasted until 1933, 1934 or 1945 (depending on how you count) and there were only two people elected into office: Ebert, who died in office in 1925 and Hindenburg. Hindenburg was reelected once in 1932 but died in office in 1934. (Thereafter, Hitler took charge of both the office of chancellor and president, but that is another story.)

If the modern German constitution is limiting the terms of the federal president because of the experiences with Weimar, it is not doing a good job. Hindenburg would have been able to have exactly the same terms in office and the single reelection he enjoyed. Instead, the so-called constitutional safeguards are not giving the federal president any true political power: the office de facto only performs ceremonial duties although a number of presidents have taken a slightly more active interpretation of their role in German politics.


On the other hand, there are presidential positions with real power that are still term-limited – sometimes more, sometimes less effectively: Compare the constitutions of the USA (powerful president, hard two-term limit) and Russia (powerful president; only single reelection possible but after stepping down for one term a president can be elected again, see Putin/Medvedev). In both of these cases, the term limit was introduced to limit the power of the president in some way or another and were in place years before the current office holders. For comparison, in France a term limit was not enacted until 2008 but only two presidents served two terms (the current limit) prior to 2008.


Taking all this evidence, it seems reasonable to assume that political power and limiting it cannot be the reason for enacting term limits for president.

Instead, term limiting the president in representative democracies may serve as a method to get an office holder more independent of day-to-day politics – like a supreme court judge would be desired to be. If a president could be elected over and over, they might be tempted to start pleasing those who elect them as people do get attached to offices they hold. Providing a clear term limit means that such a tactic is not going to bear fruit as there is a clear end to it anyway. This, in theory, ensures a more independent and neutral balancing institution. Indeed, in Germany the party affiliation of the president is completely irrelevant for the ruling government; it is the composition of the Bundesrat that determines how easy or hard governing is.

On the other hand, term limiting a prime minister, chancellor or whatever name the head of government goes by sounds like a much more effective way to limit personal political power. Germany certainly has had a number of chancellors that have towered over certain eras: Adenauer, Kohl and Merkel each ruled for more than a decade and each held great political power while doing so.

However, they are much closer to the actual happenings and much more susceptible to replacement not only by getting voted out of office. In Germany, chancellors can not only fail to get reelected following a general election but the parliament also has the option of retracting its support and voting for a new chancellor. This happened in 1982 when the social-liberal coalition broke apart and Kohl was elected as a new chancellor to replace Schmidt.

This may be a weak overall argument. Arguably, if a German party gained and held as much popular support as Putin’s party did in Russia, chances are that a lifetime chancellor would emerge – if they don’t trip over any petty affairs, are dropped by their own party on whose votes they depend or similar things happen. Adenauer eventually fell (or rather: was dropped) because of dissatisfaction with the ‘old man’. Brandt might have arguably become a similarly important chancellor had he not been targeted so successfully by an SED spy and had to resign. So maybe Germany was ‘just lucky’ that no strong, overarching figure established themself.

I guess the only real answer to your question will turn out to be: there’s no real reasoning, it just happens to be this way.

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